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other court, and this opinion shall not be treated as precedent
for any other case.
Respondent determined a deficiency in petitioners’ Federal
income tax for 2004 of $875. The sole issue for decision is
whether petitioner Bert A. Hedrick was an active participant in
qualified retirement plans in 2004 and was thus ineligible to
deduct a $3,500 contribution to an individual retirement account
under section 219.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts at trial and accompanying exhibits.
At the time the petition was filed, Bert A. Hedrick (Mr.
Hedrick) and Julie L. Hedrick (Mrs. Hedrick), jointly referred to
herein as petitioners, resided in Colorado.
Mr. Hedrick was employed by the Jefferson County Public
Schools (school system) for 28 years. During the time he was
employed there, Mr. Hedrick was an active participant in the
school system’s defined benefit retirement plan. He contributed
a percentage of his paycheck to a retirement account through the
plan, and his employer matched a percentage of that contribution.
He retired on May 31, 2004.
In addition to his employment with the school system, Mr.
Hedrick worked part time with the Denver Theatrical Stage
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